K Number
K181680
Device Name
ICONN Answer II Suture Anchor
Date Cleared
2018-08-09

(44 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The ICONN Answer II Suture Anchor is indicated for soft tissue reattachment procedures in the shoulder, foot, and ankle. Specific indications are as follows: Shoulder Indications: Rotator Cuff Repairs, Biceps Tenodesis Foot/Ankle Indications: Lateral Stabilization, Medial Stabilization, Achilles Tendon Repair, Hallux Valgus Reconstruction, Midfoot Reconstruction, Metatarsal Ligament Repair.
Device Description
The ICONN Answer II Suture Anchor (P/N's 147501 and 155001) is a sterile (gamma irradiation), single use implantable device made from Solvay's Zeniva® ZA-600L polyetheretherketone (PEEK) material indicated for soft tissue reattachment procedures in the shoulder, foot, and ankle. The anchor is available in two sizes (Diameter x Length): 4.75mm x 16mm and 5.5mm x 16mm.
More Information

Not Found

No
The device description and performance studies focus on the mechanical and biological properties of a physical suture anchor, with no mention of software, algorithms, or data processing that would indicate AI/ML.

Yes
The device is described as an "implantable device made from Solvay's Zeniva® ZA-600L polyetheretherketone (PEEK) material indicated for soft tissue reattachment procedures." These procedures are therapeutic interventions.

No

Explanation: The ICONN Answer II Suture Anchor is a reattachment device for soft tissue repair. Its intended use and description clearly state it is an implantable device used in surgical procedures and performance studies focus on mechanical properties and biocompatibility, not on providing diagnostic information.

No

The device description explicitly states it is a sterile, single-use implantable device made from PEEK material, which is a physical hardware component.

Based on the provided text, the device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is for "soft tissue reattachment procedures in the shoulder, foot, and ankle." This describes a surgical implant used directly in the body for structural support.
  • Device Description: The device is described as a "sterile (gamma irradiation), single use implantable device made from Solvay's Zeniva® ZA-600L polyetheretherketone (PEEK) material." This further confirms it's an implantable medical device.
  • Lack of IVD Characteristics: The description does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing samples from the human body (blood, urine, tissue, etc.)
    • Providing information about a patient's health status, diagnosis, or disease.
    • Using reagents or assays.

The device is clearly a surgical implant used for mechanical support during soft tissue repair, not a diagnostic tool used outside the body to analyze biological samples.

N/A

Intended Use / Indications for Use

The ICONN Answer II Suture Anchor is indicated for soft tissue reattachment procedures in the shoulder, foot, and ankle. Specific indications are as follows: Shoulder Indications: Rotator Cuff Repairs, Biceps Tenodesis Foot/Ankle Indications: Lateral Stabilization, Medial Stabilization, Achilles Tendon Repair, Hallux Valgus Reconstruction, Midfoot Reconstruction, Metatarsal Ligament Repair.

Product codes

MBI

Device Description

The ICONN Answer II Suture Anchor (P/N's 147501 and 155001) is a sterile (gamma irradiation), single use implantable device made from Solvay's Zeniva® ZA-600L polyetheretherketone (PEEK) material indicated for soft tissue reattachment procedures in the shoulder, foot, and ankle. The anchor is available in two sizes (Diameter x Length): 4.75mm x 16mm and 5.5mm x 16mm.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

shoulder, foot, and ankle

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies

Performance testing was conducted for both pullout characteristics and torsional properties. For pullout characteristics, the FDA's Draft Guidance Document for Testing Bone Anchor Devices (April 20, 1996) was used for guidance in side by side mechanical testing performed on the subject device and predicate for the following test modes: Anchor displacement after cyclic loading, Ultimate anchor pull-out. Pullout testing showed that the ICONN Answer II Suture Anchor performed similarly or better than the predicates or within acceptable ranges for the intended use. For insertion testing, ASTM F543-2013 was followed, specifically the sections on torsional properties (section A1 of the standard) and driving torque (section A2 of the standard) were analyzed and compared to demonstrate the device can be safely implanted. Cytotoxicity, irritation, and sensitization testing were carried out in accordance with ISO 10993/(R)2013 and all testing met acceptance criteria. For cytotoxicity, all test articles resulted in a cytotoxicity score of zero (0) with an acceptance criteria of 2 or less. For irritation, a score difference of 0.0 for the SC extract and 0.1 for the SO extract was seen, with an acceptance criteria of 0.2 or less. For sensitization, the test article extracts showed no evidence of causing delayed dermal contact sensitization, which is also the acceptance criteria. In accordance with ANSI/AAMI ST72:2016 LAL testing was conducted using the Kinetic-Chromogenic assay and the results demonstrated the test articles were

§ 888.3040 Smooth or threaded metallic bone fixation fastener.

(a)
Identification. A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.(b)
Classification. Class II.

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ICONN Orthopedics, LLC Whitt Israel CEO 400 Union Hill Drive, Suite 150 Birmingham, Alabama 35209

Re: K181680

Trade/Device Name: ICONN Answer II Suture Anchor Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth Or Threaded Metallic Bone Fixation Fastener Regulatory Class: Class II Product Code: MBI Dated: June 22, 2018 Received: June 26, 2018

Dear Whitt Israel:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrl/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for

August 9. 2018

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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Mark N. Melkerson -S

Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) TBD

Device Name ICONN Answer II Suture Anchor

Indications for Use (Describe)

The ICONN Answer II Suture Anchor is indicated for soft tissue reattachment procedures in the shoulder, foot, and ankle. Specific indications are as follows:

Shoulder Indications: Rotator Cuff Repairs, Biceps Tenodesis

Foot/Ankle Indications: Lateral Stabilization, Medial Stabilization, Achilles Tendon Repair, Hallux Valgus Reconstruction, Midfoot Reconstruction, Metatarsal Ligament Repair.

Type of Use (Select one or both, as applicable)
---------------------------------------------------

Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

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Image /page/3/Picture/0 description: The image shows the logo for "ICONN ORTHOPEDICS". The word "ICONN" is written in a sans-serif font, with the two "N"s in gray and the "O" represented by a blue circle. The word "ORTHOPEDICS" is written in a smaller font below the word "ICONN".

400 Union Hill Drive, Suite 150 Birmingham, AL 35209

510(k) SUMMARY

Submitter's Name:ICONN Orthopedics, LLC
Submitter's Address:400 Union Hill Drive
Suite 150
Birmingham, AL 35209
Submitter Contact Person:Whitt Israel
CEO
(205) 913-2068
Date Summary was Prepared:June 22, 2018
Trade Name or Proprietary Name:ICONN Answer II Suture Anchor
FDA Submission Document Number:K181680
Common or Usual Name:Suture Anchor
Classification:Class II per 21 CFR §888.3040
Product Code:MBI - Fastener, Fixation, Nondegradable, Soft Tissue
Classification Panel:Division of Orthopedic Devices
Technological
Characteristics:The ICONN Answer II Suture Anchor System suture anchors
are of similar design to the predicate and are manufactured with
the same basic material in similar sizes.
Performance Data:Performance testing was conducted for both pullout
characteristics and torsional properties. For pullout
characteristics, the FDA's Draft Guidance Document for Testing
Bone Anchor Devices (April 20, 1996) was used for guidance in
side by side mechanical testing performed on the subject device
and predicate for the following test modes:
● Anchor displacement after cyclic loading
● Ultimate anchor pull-out
Pullout testing showed that the ICONN Answer II Suture Anchor
performed similarly or better than the predicates or within
acceptable ranges for the intended use. For insertion testing,
ASTM F543-2013 was followed, specifically the sections on
torsional properties (section A1 of the standard) and driving torque
(section A2 of the standard) were analyzed and compared to
demonstrate the device can be safely implanted.
Cytotoxicity, irritation, and sensitization testing were carried out in
accordance with ISO 10993/(R)2013 and all testing met
acceptance criteria. For cytotoxicity, all test articles resulted in a
cytotoxicity score of zero (0) with an acceptance criteria of 2 or
less. For irritation, a score difference of 0.0 for the SC extract and
0.1 for the SO extract was seen, with an acceptance criteria of 0.2
or less. For sensitization, the test article extracts showed no
evidence of causing delayed dermal contact sensitization, which is
also the acceptance criteria.
In accordance with ANSI/AAMI ST72:2016 LAL testing was
conducted using the Kinetic-Chromogenic assay and the results
demonstrated the test articles were Shoulder Indications : Rotator Cuff Repairs, Biceps Tenodesis.
Foot/Ankle Indications : Lateral Stabilization, Medial Stabilization,
Achilles Tendon Repair, Hallux Valgus Reconstruction, Midfoot
Reconstruction, Metatarsal Ligament Repair.
Predicate Device:The predicate device was selected to help demonstrate
substantial equivalence of several characteristics to include
intended use, design, sizes, PEEK material, supplying the device
in the sterile state, and provision of sutures. The predicate device
is listed below:
• Arthrex PEEK Corkscrew FT (K061665)

Arthrex PEEK Corkscrew FT (K061665) .

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resulted in zero (0) positive tests of sterility which met acceptance criteria of not more than one (1) positive test of sterility. Conclusion: The submitted device has been demonstrated to be as safe, as effective, and performs as well as or better than the predicate device.